One difficulty encountered by national banking authorities during the course of the 2008 global financial crisis was identifying the ultimate parent for the trades made by various subsidiaries of dealers. To assist in...more

On February 26, the Federal Reserve Board extended until April 3 the comment period for its proposed rule to implement capital surcharges for the largest, most systemically important U.S. bank holding companies....more

On January 29, the Board of Governors of the Federal Reserve System (Board) invited public comment on a proposed rule to expand the applicability of the Board’s Small Bank Holding Company Policy Statement (Policy Statement)...more

ECON Votes in Favor of the MIF Regulation -
On January 27, the Economic and Monetary Affairs Committee ("ECON") released a press release stating that it had voted in favour of the proposed Regulation on multilateral...more

On January 29, Federal Reserve Board (Fed) invited public comment on a proposed rule to expand the applicability of the Board’s Small Bank Holding Company Policy Statement (Policy Statement) for small bank holding companies...more

The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more

Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more

The political gamesmanship has begun. According to Maxine Walters “Republicans attempted to move a package of 11 bills that contained controversial changes to provisions relating to derivatives and Volcker rule. The...more

The Board of Governors of the Federal Reserve System (the Board) recently issued an order granting the second of three statutorily permitted one-year extensions for compliance by banking entities with the requirements of the...more

On December 11, Congress passed legislation redefining the size of smaller institutions allowed to take advantage of the Federal Reserve’s Small Bank Holding Company Policy Statement from less than $500 million to less than...more

Council of EU Publishes Final Compromise Text of ELTIF Regulation -
The Council of the EU has published an "I" item note from its General Secretariat to the Permanent Representatives Committee (COREPER) which sets out...more

The Insurance Capital Standards Clarification Act of 2014 has been presented to President Obama for signature. The bill will:
Add language to Section 171 of Dodd-Frank to clarify that, in establishing minimum capital...more

A bill has been presented to President Obama for signature that will make more small bank holding companies eligible for regulatory relief. The bill directs the Federal Reserve to increase the qualifying asset threshold of...more

On December 9, the Federal Reserve Board (the “Board”) released a proposed rule (the “Proposed Rule”) to establish risk-based capital surcharges for U.S. bank holding companies identified as “global systemically important...more

The new year will bring new restrictions on banks and certain large financial institutions, as the Federal Reserve Board issued a final rule prohibiting financial companies from merging if the ratio of the resulting entity’s...more

Almost every bank and its holding company (“HC”) conduct business with each other, typically through an agreement whereby one performs services for the other in return for some consideration. The bank, for example, may...more

We all know that liquids are both good and bad. We are supposed to drink on average eight glasses of water a day for good health. However, too much alcoholic intake will get us into trouble with the law. Now, the larger...more

Discussion and Analysis -
Monday of this week was the fourth anniversary of the signing of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Like all anniversaries, it is a time for looking back. As would...more

Taxes remain a certainty in life, but in an effort to reduce confusion regarding the ownership of tax refunds—particularly in light of court opinions reaching varying conclusions when considering failed banks—the Board of...more